https://www.taxtmi.com/caselaws?id=784258 Whether an assessment order giving effect to DRP directions can be passed beyond the time limit in s.144C(13) was the dominant issue. The HC held that s.144C(13) imposes a mandatory obligation on the AO to complete the assessment within one month from the end of the month in which the DRP directions are received; statutory timelines cannot be waived, and the AO is strictly bound to act in the manner prescribed. Applying its earlier decision in the anonymized assessee's own case, the HC held that proceedings to make the transfer pricing addition stood barred by limitation once the s.144C(13) period expired, and the AO could not thereafter invoke s.144C(13) to complete the assessment. en-us Mon, 22 Dec 2025 00:00:00 +0530 Wed, 31 Dec 2025 11:04:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784258 Whether an assessment order giving effect to DRP directions can be passed beyond the time limit in s.144C(13) was the dominant issue. The HC held that s.144C(13) imposes a mandatory obligation on the AO to complete the assessment within one month from the end of the month in which the DRP directions are received; statutory timelines cannot be waived, and the AO is strictly bound to act in the manner prescribed. Applying its earlier decision in the anonymized assessee's own case, the HC held that proceedings to make the transfer pricing addition stood barred by limitation once the s.144C(13) period expired, and the AO could not thereafter invoke s.144C(13) to complete the assessment. Case-Laws Income Tax Mon, 22 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784258